Statement on Proposed USDA Bioengineered Food Disclosure Rule

By Alliance for Biotech Facts

“Products enhanced through biotechnology are as safe and healthy as any food on the shelf, in the fridge, or at the produce stand. The Alliance believes consumers should be informed when food contains genetic material introduced through bioengineering.  However, products—such as pure oils, starches, and sugars—that may come from crops enhanced through bioengineering, but contain no genetic material, are no different from other safe and healthy foods, and should not require labeling.”—Dan Foster, for the Alliance for Biotech Facts

WASHINGTON, DC – The United States Department of Agriculture’s (USDA) proposed rule for the National Bioengineered Food Disclosure Standard allows the public the opportunity to provide comments on several key issues. We welcome the release of the proposed rule so that an open and fact-based discussion about the key issues may formally begin. 

The safety of crop biotechnology has been established by numerous international and domestic scientific and regulatory bodies including the National Academies of Science, Engineering and Medicine, the U.S. Food and Drug Administration (FDA), the American Medical Association, and the World Health Organization.

The clear intent of the law passed by Congress requires disclosure only when foods contain genetic material introduced through bioengineering. Pure oils, starches, and sugars that may come from crops enhanced through bioengineering are no different from other safe and healthy foods. Since these foods are no different from other foods, different labeling should not be required. By contrast, a government mandated label singling out these pure ingredients would wrongly signal to consumers that there is something different or unusual about these products. Therefore, the Alliance supports Position 1 for the definition of “bioengineered food.”

Further, the Alliance supports a threshold of 5 percent for triggering mandatory disclosure for food and beverage products, again recognizing this is a marketing rather than food safety standard. This amount is consistent with USDA’s National Organic Standard, and with other countries around the world, including Indonesia, Japan, South Africa, Thailand and Vietnam. A lower threshold for disclosure would substantially increase compliance costs, disrupt supply chains and raise food costs for everyone. The Alliance supports “Alternative 1-C” in the “Threshold” section of the proposed rule, which discusses a cumulative 5 percent threshold.

The Alliance does not believe that products developed through gene editing should be subject to mandatory disclosure when they do not meet the requirements for disclosure. Products developed through gene editing often can be found in nature or achieved through more traditional breeding methods. Gene editing is an efficient method of plant breeding that allows plant breeders to work within the plant’s own family to achieve desired characteristics without introduction of foreign DNA. Again, when the food is no different than food from conventionally produced plants, no difference in labeling should be required.

Finally, the Alliance looks forward to participating in an open and fact-based discussion about this rule-making process.


The Alliance for Biotech Facts represents tens of thousands of farmers, producers, and food manufacturers who stand to be impacted by the National Bioengineered Food Disclosure Standard. Our members include the American Farm Bureau Federation, the American Soybean Association, the American Sugarbeet Growers Association, the Corn Refiners Association, and the National Corn Growers Association. The Alliance is committed to ensuring that the scientific consensus on the safety and benefits of bioengineering in agriculture guides the policymaking.